3.4 Environmental compliance approach

 The prerequisite for classification as "potentially containing Hazardous Materials" (PCHM) is "a comprehensible justification such as the impossibility of conducting sampling without compromising the safety of the ship and its operational efficiency" (paragraph 4.2.3 of the 2011 Guidelines for the Development of the Inventory of Hazardous Materials, hereafter "the Inventory Guidelines").

 The SRFP should describe how PCHMs will be treated; either:

• they will be removed, stored and treated as Hazardous Materials in accordance with the requirements of the Convention; or
• sampling and analysis will be conducted and PCHMs will be treated accordingly, based on the findings of sampling and analysis.

 The basis of such a decision on how to treat PCHMs should be transparent and consistent as far as practicable. This information will need to be fully described in the Ship Recycling Plan.

 If, during the recycling process or in preparation for it, the Ship Recycling Facility deems it necessary, sampling, analysis and/or visual inspection should be conducted, possibly with the cooperation of the shipowner, to enable the identification of Hazardous Materials. A sampling plan should be developed describing the sampling locations, number of samples to be taken, the name of the sampler (including subcontractors) and the type of analysis to be performed.

 When conducting the sampling of any possible Hazardous Materials, the samplers should be protected from exposure by the worker-safety measures required for the Hazardous Materials in question. Analysis of the samples should be performed by an accredited laboratory.

 It is recommended that, in conducting additional sampling, the Ship Recycling Facility should follow the relevant part on sampling and analysis of the Inventory Guidelines.

 After the sampling and analysis results are known, the Ship Recycling Facility should manage the materials appropriately according to whether they have been found to be hazardous.

 The Ship Recycling Facility should utilize the information in the IHM for the purposes of identifying the type, location and quantity of any Hazardous Materials and for marking and/or labelling. Asbestos, PCBs, other Hazardous Materials and ship tanks – such as crude oil tank (COT), fuel oil tank (FOT), lubricating oil tank (LOT), fresh water tank (FWT) and water ballast tank (WBT) – should be clearly marked in an easily identifiable manner.

 It is recommended that the Ship Recycling Facility should ensure that it is fully aware of all the potential locations of Hazardous Materials on board ships. Examples of typical locations for many of the Hazardous Materials are provided in section 2.2 ("Indicative List") of appendix 5 ("Example of the Development Process for Part I of the Inventory for Existing Ships") of the Inventory Guidelines.

 The SRFP should describe how to safely remove, handle and/or clean the Hazardous Materials that have been identified on the ship, taking account of their potential adverse effects on human health and/or the environment.

 Removal of Hazardous Materials should only be conducted by appropriately trained personnel following the worker-safety measures required for the Hazardous Materials in question.

 Whenever in use, the space where the removal work is occurring should be isolated from other work spaces and should be clearly marked to inform all persons of the hazards in the area.

 After the removal of highly toxic, explosive or reactive Hazardous Materials, decontamination or remediation of the space should be performed by trained personnel.

 Methods and procedures for the removal, handling and remediation of Hazardous Materials should be established to ensure safe and environmentally sound operations in accordance with the applicable national requirements.

 Pursuant to section 2.2 of the Supplement to the Document of Authorization to conduct Ship Recycling (DASR) (appendix 5 of the Convention), the SRFP should indicate the responsible personnel authorized to carry out removal of Hazardous Materials, with the certificate number or other relevant information, for each of the Hazardous Materials identified.

 In the normal handling of all hazardous materials due attention should be paid to relevant occupational exposure limits.

 The SRFP should describe how all wastes generated from recycling activity will be kept separate from recyclable materials and equipment, labelled for clear identification and stored in appropriate conditions either temporarily or for a longer term. The SRFP should describe how the Ship Recycling Facility will avoid waste being mixed or contaminated in a way that interferes with subsequent handling, storage, treatment, recycling or disposal.

 The SRFP should demonstrate how the Ship Recycling Facility will ensure environmentally sound management of all Hazardous Materials and wastes removed from a ship at the Ship Recycling Facility. If treatment or disposal is taking place at the Ship Recycling Facility, the SRFP should describe how the materials will be managed in an environmentally sound manner and in compliance with applicable national requirements.

 In situations where the Hazardous Materials and wastes are sent off site, the SRFP should describe procedures to ensure that they are transferred only to a facility authorized to deal with their safe and environmentally sound treatment and disposal.

 The SRFP should identify all off-site management and disposal facilities, describe how the materials will be managed at those facilities and identify all authorizations, permits, certificates, approvals and licences required by national and other agencies authorizing the facilities to manage the wastes. The SRFP should include procedures for tracking Hazardous Materials and wastes as they are transported from the Ship Recycling Facility to their ultimate destination, and for managing and storing documentation, including that of subcontractors.

 The final waste-management facilities should adhere to national standards and requirements which should take into account applicable international standards and requirements.

 The Ship Recycling Facility should identify the location and quantity of asbestos and materials containing asbestos by actively utilizing the IHM. Identification, marking and labelling should be conducted by the Ship Recycling Facility before asbestos and materials containing asbestos are removed.

 Indicative lists of shipboard locations for asbestos are provided in the Inventory Guidelines (section 2.2.2.1 of appendix 5), and can be used as supporting material if additional assessment and sampling are required.

 In order to safely remove asbestos and materials containing asbestos, the following protective measures should be taken, and the SRFP should describe how they are implemented by the Ship Recycling Facility:

• .1 workers should be present who are trained and authorized in the removal of asbestos and materials containing asbestos in accordance with applicable national requirements;

• .2 the removal of the asbestos and materials containing asbestos should be conducted under the monitoring and management of the Competent person;

• .3 the number of workers exposed to asbestos should be limited to the necessary minimum;

• .4 the area in which the removal of asbestos and materials containing asbestos is to be conducted should be isolated from the other work areas, and entry should be allowed only to appropriately trained personnel. The area should be clearly posted with a caution that asbestos removal work is occurring;

• .5 if the removal work includes cutting, boring, grinding or otherwise disturbing friable asbestos and materials containing asbestos which may scatter into the environment, appropriate protection should be provided, so as not to release the asbestos in the air, by isolating the area in the room or space where the removal will occur; a common approach is as follows:

  • seal the room or space with plastic sheets;
  • the plastic sheets should be of sufficient strength;
  • where the machines, equipment, pipes or spaces cannot be isolated or sealed (for example, a complex and narrow area under a floor plate in the engine room), partial protection may be provided with plastic sheets;
  • the isolated area should be maintained under negative pressure where possible; and
  • practices for dealing with materials containing asbestos under a partial pressure chamber system and the use of wet methods should be encouraged as far as possible;

• .6 materials containing friable asbestos in areas such as walls and ceilings should be carefully removed, and water or an appropriate wetting agent should be applied prior to the removal of materials containing asbestos in order to prevent the asbestos from scattering into the atmosphere;

• .7 personal protection equipment (PPE) for workers, including respiratory protection and special protective clothing for asbestos, should be provided;

• .8 after removal of asbestos, the area should be cleaned in the following manner:

  • equipment and tools should be washed/cleaned and then removed from the area;
  • the asbestos and materials containing asbestos should be packed and sealed in plastic containers prior to being removed from the area;
  • the plastic sheets used for isolating the area should be moistened with water and handled carefully to prevent the asbestos from scattering;
  • an efficient vacuum cleaner should be used for cleaning the area, such as one equipped with a high efficiency particulate air (HEPA) filter; and
  • the airborne asbestos in the air and/or space should be checked before removing the plastic isolation sheets and allowing other work to continue in the area;

• .9 workers removing asbestos should properly prepare for entry into a contaminated area, and should be decontaminated before leaving the contaminated area, as follows:

  • workers should not be allowed to wear street clothes in the isolated area or under their PPE;
  • after completing work in the isolated area, workers should shower to remove asbestos, and then enter a separate clean area to put on their clothes; and
  • work clothes should not be laundered at home; they should be bagged, labelled and laundered at an appropriate location at the Facility or off site;

• .10 containers used for packing and transporting the removed asbestos materials should be properly labelled and sufficiently strong and resilient as to minimize the possibility of accidental damage or breakage during transport, which could result in the uncontained release of asbestos fibres into the atmosphere; and

• .11 asbestos should not be reused or recycled, and its management and final disposal should comply with national requirements.

 The Ship Recycling Facility should identify the location and quantity of the Hazardous Materials and wastes containing PCBs (polychlorinated biphenyls) by actively utilizing the IHM.

 Indicative lists of shipboard locations for PCBs are provided in the Inventory Guidelines (section 2.2.2.2 of appendix 5), and can be used as supporting material if additional assessment and sampling are required. PCBs may be contained in the equipment and materials in both solid and liquid forms as shown on the IHM. Since PCB sampling and analytical procedures can be expensive and time consuming, it may be more economical to presume that the materials do contain PCBs and remove and manage them accordingly.

 In order to safely remove PCBs and materials containing PCBs, the following protective measures should be taken and the SRFP should describe how they are implemented by the Ship Recycling Facility:

• .1 workers should be specifically trained and authorized in the removal of PCBs;

• .2 personal protection equipment (PPE) for workers, including respiratory protection and dermal protection, should be provided;

• .3 removal of Hazardous Materials and wastes containing PCBs should be carefully performed to avoid spills, volatilization or scattering, in the following manner:

  • spill prevention measures should be taken when draining or removing liquid-filled equipment, including booms, drip pans, liners and/or absorbent materials placed around the system or piece of equipment; and
  • most solid materials containing PCBs can be removed by using manual, chemical or mechanical means such as blasting, scraping, cutting, stripping or gouging;

• .4 thermal or "hot" methods of removal or recycling should not be used if the presence of PCB is known or suspected (for example, electric cable insulation, hydraulic oil, transformer oil and paints containing PCBs should not be burned);

• .5 equipment used to remove PCB-containing materials should be decontaminated appropriately after use (a common decontamination process for equipment would be to rinse with non-polar organic solvent such as kerosene or diesel, then wash with soap and water and rinse with clean water); any water or other liquid used should be appropriately managed as waste;

• .6 removed PCBs and materials containing PCBs should be appropriately stored in properly labelled, leak-proof containers that are made for transport and are sealed (liquids) or covered (solids);

• .7 a separate storage area should be set up for PCB wastes, in accordance with the following points:

  • Hazardous Materials and wastes containing PCBs should not be stored or kept with other Hazardous Materials and wastes;
  • the storage area should be clearly marked on the exterior with warnings that it contains PCBs;
  • the storage area should provide protection from rain; and
  • containers should be regularly inspected for leaks and damage;

• .8 containers or vehicles used for packing and transporting the removed PCB materials should be properly labelled and the possibility of accidental release during transport should be minimized; and

• .9 PCBs should not be reused or recycled and their management and final disposal should comply with national requirements.

 The Ship Recycling Facility should identify the location and quantity of ozone-depleting substances (ODSs) prior to removal by actively utilizing the IHM.

 The indicative list for ODSs in the Inventory Guidelines (section 2.2.2.3 of appendix 5) can be used as the supporting material if an additional survey and sampling are required.

 The SRFP should describe how the Ship Recycling Facility implements the following protective measures to safely remove and manage ODSs:

• .1 extraction of ODSs from the system should be done by persons who are trained and authorized for handling such materials;

• .2 ODSs on board in containers, equipment and piping systems should not be released into the atmosphere;

• .3 management or destruction of ODSs should comply with national requirements; and

• .4 ODSs used as blowing agents and trapped in insulation foam in refrigerated areas should not be released into the atmosphere and environmentally sound management should be observed while dismantling and disposing of the foam waste.

 The SRFP should describe procedures for properly managing any paints and coatings that are highly flammable or that may release toxins during cutting.

 The Ship Recycling Facility should identify the location and volume of hazardous liquids remaining on board by actively utilizing the IHM. Identification, marking and labelling of the tanks and other areas should be conducted by the Ship Recycling Facility before the liquids are removed.

 The residual oil storage tank should be protected against leakage, overflow, fire and other potential accidents.

 Hazardous liquids, residues and sediments in stores, tanks, machines, equipment and piping should be removed under safe and environmentally sound conditions.

 Ballast water should be handled in accordance with relevant national requirements.

 As indicated in the Inventory Guidelines, heavy metals are found in batteries, galvanized materials, level switches, gyro compasses, thermometers, coatings, etc. Radioactive substances may be found in level indicators and smoke detectors.

 Equipment and other instruments containing heavy metals should be removed carefully to ensure that they do not break and to avoid contamination of the environment. Reusable equipment and instruments should be stored properly. Broken equipment and instruments should be delivered to the appropriate companies for repair, recycling or disposal in accordance with national requirements.

 Anodes fitted to the ship's hull as sacrificial metal should be removed in the course of block cutting and should be managed properly.

 Other Hazardous Materials not listed above and which are not part of the ship's structure – those materials listed in the IHM, Parts II and III – should be removed under safe conditions.

 To the maximum extent possible, these materials should be removed prior to cutting according to the provisions of national laws and regulations. After the materials have been removed from ships, safe and environmentally sound methods should be used for storing and processing them; for example, electric cable insulation containing chlorinated compounds should not be burned.

 The purpose of developing and implementing a programme for spill prevention, control and countermeasures is to minimize the risk of spills and leaks that could adversely impact the environment. The SRFP should include a programme that defines the Ship Recycling Facility's procedures for spill prevention, response and countermeasures. The programme should define proactive approaches to spill prevention and procedures to be implemented in the event of spills.

 At a minimum, the programme should demonstrate that the Ship Recycling Facility has adequate containment and spill clean-up equipment and procedures, by identifying the following:

• containment and diversionary structures in place to prevent discharged Hazardous Materials from contaminating soil and water;
• Facility drainage areas;
• location of spill response equipment;
• environmental protection measures to be implemented during transfer and offloading of fuels;
• location of other oils and bilges;
• fuel storage locations;
• inspection and record-keeping procedures;
• security measures;
• personnel training programmes;
• spill prevention and reporting procedures; and
• the history of incidents at the Ship Recycling Facility.

 As part of the procedures for spill prevention, response and countermeasures, the SRFP should identify the designated in-house and subcontracted personnel who will be responsible for managing the programme and for responding to spills or similar emergencies, as well as the local authorities (such as the fire department) that may have jurisdiction at the Ship Recycling Facility. This SRFP should include 24-hour contact information. The SRFP should include both a narrative and graphic description of the Facility layout, including the location of any water bodies or other routes of migration, the storage location of oil or other Hazardous Materials, procedures for fuel transfer from ship to shore, procedures to be implemented in the event of a spill and the types and locations of emergency-response equipment (such as absorbent materials, personal protective equipment and first-aid equipment).

 By identifying the potential sources of spills or leaks, the Ship Recycling Facility can then identify proactive measures to be implemented in order to minimize the risk associated with Facility activities. It is helpful for the Ship Recycling Facility to review the potential sources for spills and leaks and to determine the types of failures associated with them in order to determine the most appropriate and effective prevention measures. For example, drums should not be left open unless being filled, should be within a secondary containment or beamed structure and should not be exposed to rainfall that could corrode them over time.

 The programme for spill prevention, control and countermeasures can be used as a tool by the Ship Recycling Facility to communicate practices on preventing and responding to spills and leaks, as a resource during emergency response and as a repository for information on storage, inspection and testing. It is important to maintain records on maintenance, inspections and employee training. Periodic review of the programme for spill prevention, control and countermeasures is also an effective tool for determining which procedures are fulfilling their intended function and for identifying weaknesses in the programme.

 Storm-water run-off from industrial facilities has the potential to adversely affect the environment. Improper storage and handling of Hazardous Materials and wastes could increase the risk of environmental degradation through contact with water. The SRFP should include a programme that defines measures to be implemented and maintained to minimize the potential for storm-water contamination at the Ship Recycling Facility.

 A programme for the prevention of storm-water pollution should include the identification of all potential pollutant sources at the Ship Recycling Facility that could come into contact with storm water, with the nearby receiving waters and with storm water-conveyance systems. A site map should be developed that depicts such information.

 Following compilation of the relevant site information, an assessment should be conducted in order to determine the appropriate control measures. Control measures should be implemented to reduce the threat of storm-water pollution, to control erosion and sediment and to protect nearby natural resources. Control measures can include best management practices, maintenance and inspection programmes, employee training and reporting.

 As an example, a potential pollutant source at a Ship Recycling Facility is the storage of drums, tanks or other containers for the offloading of fuel from a ship. The activity of transferring and storing the fuel includes multiple potential pollutant sources, such as spills and leaks during transfer to the water or the ground, leaking drums or containers or run-off from the drum storage area. Control measures to minimize the risk to the environment from storm-water contamination could include storing drums and other containers under semi-permanent or permanent coverings, controlling spills or run-off from drum storage areas with appropriately sized secondary containment, conducting routine inspections of drum storage areas and establishing appropriate clean-up procedures in the event of spills or leaks.

 The development of preventive measures is the most effective way to minimize the discharge of pollutants via storm water. It is important to maintain records on maintenance, inspections and employee training. Periodic review of the storm-water management programme is also an effective tool for determining which best management practices are fulfilling their intended function and for identifying weaknesses in the programme.

 The introduction of debris into the marine environment by ship recycling activities has the potential to adversely affect the environment. The SRFP should include a programme that defines measures to be implemented and maintained to minimize the potential for debris deposition into the water, including the maintenance of areas from which debris might be transported into the marine environment by wind, storm drains, tides or run-off. Control measures should be implemented to reduce the likelihood of debris deposition.

 The SRFP should describe the procedures for reporting incidents and spills, including at a minimum the following information:

• how duties and responsibilities are assigned to the Ship Recycling Facility's responsible team, department or persons and their reporting responsibilities in the event of an incident;
• how the reporting procedures relate to the emergency preparedness and response plan (EPRP);
• communication link to the local community for any necessary assistance; and
• procedures for providing information to the public and for carrying out post-incident surveys and releasing post-incident reports.